This is in response to your letter dated May 11, regarding the International
Agency for Research on Carcinogens (IARC) listing of boot and shoe
manufacturing and repair as an occupation causally associated with cancer in
humans.

The Hazard Communication Standard (HCS) states that "chemical manufacturers,
importers, and employers evaluating chemicals shall treat the following
sources as establishing that a chemical is a carcinogen or potential
carcinogen for hazard communication purposes:

Since IARC lists boot and shoe manufacturers in Supplement 4, OSHA included
it (Table 1 Appendix D of CPL 2-2.38A CH-2) in the group of industrial
processes and occupational exposures causally associated with cancer in
humans. This was for informational purposes to alert our field people that
carcinogenic chemicals may be found in this industry. As indicated in Note 2
under Table 1 "these are processes on occupational exposures and are not
specific chemicals." In addition Note 2 states that "the labeling
requirements of the HCS will not usually apply unless a specific chemical
from the process has been identified elsewhere by IARC, NTP or OSHA as a
hazardous chemical." (Underlining added.) Therefore, from a compliance
standpoint, only those chemicals which are specifically listed by IARC or NTP
or regulated by OSHA would be subject to the requirements of the HCS.

OSHA Instruction CPL 2-2.28A provides only general guidance to our
compliance officers to assist them in making HCS inspections. Appendix D was
added to the Instruction in order to make the IARC and NTP lists more
accessible to them in the field.

Since the inclusion of industries in our guidelines does not enhance or
significantly contribute toward increasing the efficiency of our enforcement
program, they will be removed from the directive during the next general
revision.

I hope I have fully addressed your concerns. If I can be of further
assistance please feel free to contact me again.

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